WHISTLEBLOWING POLICY

General Overview
Gaulbridge Limited (“Gaulbridge”, “the Firm”, “we”, “us”, “our”) is committed to maintaining the highest standards of integrity, transparency, and ethical business conduct. We encourage the reporting of genuine concerns relating to misconduct, wrongdoing, or breaches of legal or regulatory obligations through a secure and effective whistleblowing framework.

This Policy is designed to enable employees, contractors, clients, and other stakeholders to raise concerns in good faith, without fear of retaliation, and with the assurance that such concerns will be handled confidentially, fairly, and appropriately.

The whistleblowing framework aims to:
Provide a confidential and secure mechanism for reporting concerns relating to misconduct, regulatory non-compliance, or unethical behaviour
Ensure all reports are assessed and investigated promptly, independently, and proportionately
Protect whistleblowers from retaliation or adverse treatment
Support Gaulbridge’s governance, compliance, and risk management obligations
Align with applicable Canadian laws, regulatory expectations, and recognised international best practices

Scope and Applicability
This Policy applies to all individuals who interact with Gaulbridge, including:
Employees, executives, and directors
Contractors, consultants, agents, and third-party service providers
Clients, vendors, and other external stakeholders

Concerns that may be reported under this Policy include, without limitation:
Breaches of laws, regulations, or regulatory requirements (including AML/CTF, sanctions, and financial crime obligations)
Fraud, theft, misrepresentation, financial misconduct, or misuse of company or client assets
Conflicts of interest, bribery, corruption, improper inducements, or abuse of authority
Harassment, discrimination, bullying, or serious workplace misconduct
Information security incidents, unauthorised disclosures, data misuse, or mishandling of confidential information
Any conduct that may materially harm Gaulbridge’s integrity, reputation, clients, or regulatory standing

This Policy is not intended to replace normal grievance or complaints procedures for routine employment or service-related matters.

Reporting Procedures and Confidentiality
Gaulbridge provides secure and confidential channels for raising whistleblowing concerns:
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Concerns may be reported through any of the following means:
Dedicated compliance email: compliance@gaulbridge.com

Written correspondence (including anonymous submissions):
Gaulbridge Limited
Office 301410 W Georgia Street,
5th FloorVancouver,
BCV6B 1Z3
Canada

Direct reporting:
Concerns may also be raised directly with the Compliance Officer or a designated senior officer, either in writing or via an arranged meeting.
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Confidentiality and Anonymity
All whistleblowing reports are treated as confidential and handled with discretion.
Whistleblowers may submit reports anonymously. Where a whistleblower’s identity is known, it will be protected to the fullest extent permitted by law.
Disclosure of a whistleblower’s identity will not occur without consent, except where disclosure is required by law, regulatory obligation, or is necessary to facilitate a lawful investigation.

Submission of Reports
To support effective assessment and investigation, whistleblowers are encouraged (but not required) to provide:
A clear description of the concern or suspected misconduct
Names of individuals involved (if known)
Relevant dates, times, and locations
Any available supporting evidence (documents, emails, screenshots, records, transaction references)
Whistleblowers are not required to prove their concerns.
Reports should be made in good faith and based on reasonable belief.

Investigation ProcessInitial Acknowledgement and Assessment
Where contact details are provided, Gaulbridge will acknowledge receipt of a report within two (2) business days.
Anonymous reports may be assigned a reference identifier where feasible.
An initial assessment will determine whether:

The matter falls within the scope of this Policy
A formal investigation is required
Additional information is necessary
Formal Investigation
Where appropriate, a formal investigation will be conducted by the Compliance function or an independent investigator.

Investigations may include:
Review of relevant records, systems, and communications
Interviews with relevant individuals
Independent analysis by personnel not involved in the reported matter
Where concerns involve suspected criminal conduct, serious regulatory breaches, or legal violations, Gaulbridge may escalate the matter to appropriate regulators or law enforcement authorities, as required or permitted by law.

Resolution and Corrective Actions
Following an investigation, Gaulbridge will determine appropriate actions, which may include:
Disciplinary measures (including warnings, suspension, termination of employment or contracts)
Process, policy, or control enhancements
Regulatory notifications or legal action where required
Where lawful and appropriate, a whistleblower may be provided with a high-level update on the outcome, subject to confidentiality and legal constraints.

Whistleblower Protection and No Retaliation
Gaulbridge has a zero-tolerance policy toward retaliation against individuals who raise concerns in good faith.
Retaliation includes, but is not limited to:

Termination, demotion, suspension, or adverse role changes
Harassment, intimidation, threats, or pressure
Unjustified disciplinary action or unfavourable treatment
Any individual who experiences or witnesses retaliation should report it immediately through the channels above.

Allegations of retaliation will be investigated and may result in disciplinary action.
Knowingly false, malicious, or deliberately misleading reports may result in disciplinary or contractual consequences. No action will be taken against a whistleblower solely because a concern is not substantiated.

Reporting, Record-Keeping, and Oversight
All whistleblowing reports, investigation records, and outcomes are securely stored with restricted access and retained for a minimum of eight (8) years, or longer where required by law or regulatory obligations.

Gaulbridge ensures that:
Records are accessible only to authorised personnel
Periodic anonymised summaries may be provided to senior management or the Board for governance oversight
Information may be disclosed to regulators or authorities where legally required

Ongoing Review and Monitoring
This Policy is reviewed at least annually and updated as necessary to reflect:
Changes in laws or regulatory expectations
Material changes to Gaulbridge’s business or risk profile
Lessons learned from whistleblowing cases
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As part of Gaulbridge’s compliance framework:
Staff training promotes ethical conduct and awareness of reporting channels
Periodic audits and controls testing support effectiveness and confidentiality

Contact
For questions regarding this Policy or whistleblowing procedures, please contact us via email: compliance@gaulbridge.com